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TRANSCRIPT
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Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S1
Page 1 of 2
Witness: BOLDT John
Rogers Communications Interrogatory #S1 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Ex H1 - Joint Use Charges (31-Mar-2017) 8
Ex H1 - Joint Use Charges (07-Jun-2017) 9
Pole Rate Calculations (28-May-2018) 10
Pole Rate Work Form 11
EB-2015-0141 Decision 12
13
Interrogatory: 14
1. We have inserted the values provided by Hydro One throughout this proceeding in the 15
following table. Please confirm the values shown and complete the table by filling in the 16
missing values. 17
18
EB-2015-
0141
Decision
Ex H1 - Joint
Use Charges
(31-Mar-2017)
Ex H1 - Joint
Use Charges
(07-Jun-2017)
Pole Rate
Calculations
(28-May-2018)
Pole Rate
Calculations
(28-May-2018)
2014
actuals 2015 actuals 2016 actuals
2017
actuals
2018
forecast
DIRECT COSTS
Admin Costs $0.90 $ 0.92 $ 0.93 $1.59
Loss in productivity $3.09 $ 3.15 $ 3.18 $3.20
Total Direct Costs $3.99 $ 4.07 $ 4.11 $4.79
INDIRECT COSTS
Net embedded cost $944.49 $1,058.06 $1,178.33 $1,237.22 $1,290.58
Depreciation rate
1.82% 1.82%
Pre-tax carrying cost 8.49% 7.87% 7.79%
7.49%
Depreciation cost $23.83 $25.77 $28.47 $31.97 $ 33.35
Pole maintenance $4.69 $3.92 $4.08 $7.13 $7.25
Capital carrying cost $80.19 $83.27 $91.79 $ 96.66
Total Indirect Costs $108.71 $112.96 $124.34 $137.26
ALLOCATION
No. of attachers 1.3 1.3 1.3 1.38 1.35
Allocation factor 34.3% 34.3% 34.3% 30.57% 31.24%
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S1
Page 2 of 2
Witness: BOLDT John
Allocate Indirect costs $37.29 $38.75 $42.65 $ 42.88
Calculated rate $41.28 $42.82 $46.76 $47.67
Adjust to 2018 $43.99 $47.43 $47.67
1
Response: 2
3
EB-2015-
0141
Decision
Ex H1 - Joint
Use Charges
(31-Mar-2017)
Ex H1 - Joint
Use Charges
(07-Jun-2017)
Pole Rate
Calculations
(28-May-2018)
Pole Rate
Calculations
(28-May-2018)
Determined
using Old
Methodology
Determined using OEB
Methodology,
described in EB-2015-0304
2014 actuals 2015 actuals 2016 actuals
2017
actuals
2018
forecast
DIRECT COSTS
Admin Costs $0.90 $ 0.92 $ 0.93 $1.601 $1.59
Loss in productivity $3.09 $ 3.15 $ 3.18 $3.20 $3.222
Total Direct Costs $3.99 $ 4.07 $ 4.11 $4.80 $4.81
INDIRECT COSTS
Net embedded cost $944.49 $1,058.06 $1,178.33 $1,237.22 $1,290.58
Depreciation rate 1.7% 1.7% 1.7% 1.82% 1.82%
Pre-tax carrying cost 8.49% 7.87% 7.79% 7.33%3 7.49%
Depreciation cost $23.83 $25.77 $28.47 $31.97 $ 33.35
Pole maintenance $4.69 $3.92 $4.08 $7.13 $7.25
Capital carrying cost $80.19 $83.27 $91.79 $90.69 $ 96.66
Total Indirect Costs $108.71 $112.954 $124.34 $129.79 $137.26
ALLOCATION
No. of attachers 1.3 1.3 1.3 1.38 1.35
Allocation factor 34.3% 34.3% 34.3% 30.57% 31.24%
Allocate Indirect costs $37.29 $38.744 $42.65 $39.68 $ 42.88
Calculated rate $41.28 $42.784 $46.75
4 $44.48 $47.69
2
Adjust to 2018 $43.995 $47.43
5 $45.01 $47.69
2
4
1 $9,000 (as filed in 1-54-VECC-S130(a)) + $1,151,190 (as filed in I-54-VECC-S131(c)) 2 As corrected in I-54-VECC-134(c) 3 Refer to I-54-VECC-S140(b) 4 Amount corrected as it did not correspond to filed evidence. 5 This rate was determined using the Old Methodology and is not comparable to the rates determined by the New Methodology.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S2
Page 1 of 4
Witness: BOLDT John
Rogers Communications Interrogatory #S2 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Responses to Rogers Interrogatories 8
9
Interrogatory: 10
1. In Rogers-03(1), we asked you to provide the 2017 average Net Embedded Cost (NEC) and 11
the average current installed cost for various sizes of poles. You responded as follows: 12
13
Hydro One does not track installed value per pole length. Hydro One’s average pole cost in 14
all types of situations, and setting conditions, for the yearly pole replacement program for 15
2016 is $8,350. 16
17
a) Is this response still valid? 18
19
b) If you do not track installed value per pole length, what do you track with respect to the 20
installed costs of your poles? 21
22
c) If you do not track installed value per pole length, how did you come up with an average 23
value of $8,350 for 2016? Is this a weighted average? What is it based on? Please show the 24
calculation you used to come up with this value. 25
26
d) You claim that you do not track installed value per pole length, but if your auditors, 27
shareholders or the Board were to ask you how much more expensive it is to install a 50-foot 28
pole with multiple power facilities versus a 40-foot foot pole with only single power facilities 29
(on average and under similar installation conditions), what information would you provide? 30
31
e) For the purpose of this question, assume the most common installation conditions for a pole 32
in Hydro One’s territory. If we assign a value of 100% as a baseline for the installation costs 33
(materials and labour) of a 40-foot pole, provide the relative installation costs, as a 34
percentage of the 40-foot pole, for the other lengths of joint use poles. Please use 2017 35
values. 36
37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S2
Page 2 of 4
Witness: BOLDT John
Pole Height Installed Cost
Relative to 40’ pole
<=25
30
35
40 100%
45
>=50
1
2. In Rogers-03(3), we asked you to describe under what circumstances poles other than the 2
standard 40-foot pole would be used. While we understand that any size of pole can 3
accommodate a telecom attachment, it would appear that each size or type of pole is designed 4
for a particular purpose or application. Under this assumption, we have attempted to interpret 5
and reproduce your responses in the table below in order to describe the primary or principle 6
application of each type of pole. Please review this table and confirm that we have done so 7
properly. If we have not done so, please make the necessary corrections. 8
9
Pole Height Primary purpose or application
<=25 - Secondary power and telecom service poles
- Backlot construction (No vehicle access)
30 - Secondary power and telecom service poles
- Backlot construction (No vehicle access)
35 - Secondary power and Telecom service poles
- Road crossing
35 - Guying poles for road crossings (stub pole)
40 - Standard LDC/Telecom JUP
- Side of a road
45 - Standard LDC/Telecom JUP
- Road or highway crossing
50 - Standard LDC/Generator JUP
- Along the side of a road
55-60 - Standard LDC/Generator JUP
- Road or highway crossing
Above 65 - LDC/Generator JUP (HONI + multiple circuits)
- Deep ditches and ravines
3. In Rogers-03(4), we asked you why telecom attachers should contribute to the costs of larger 10
poles in circumstances where they do not require the additional height, and you responded as 11
follows: 12
13
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S2
Page 3 of 4
Witness: BOLDT John
For long road crossings, and in designing at maximum sag, poles above 40 ft. need to be 1
used to allow the carrier to be able to stay a safe distance above the ground. This is also the 2
case when crossing a road that has deep ditches, as well as when running parallel to a 3
highway to cross driveways, or obstacles. 4
5
a) Is this response still valid? 6
7
b) Of the total number of poles 50 feet or higher, how many are required for clearance issues 8
(i.e., road crossings, deep ditches and ravines)? 9
10
4. Please provide the total number of telecom attachers per joint use pole for each size of pole 11
listed for the years 2017 and 2018 (forecast). 12
13
Pole Height 2017 2018
<=25
30
35
35
40
45
50
55-60
Above 65
14
Response: 15
1. 16
a) Yes 17
18
b) In USoA 1830, we track the total capitalized cost of all poles and fixtures less any customer 19
contribution. 20
21
c) The calculation that underpins the data for Pole Replacement Gross Cost per unit is found in 22
Exhibit B1-1-1 DSP 1.4 page 6. 23
24
d) – e) 25
The OEB’s Procedural Order 8 (“PO8”) provides for interrogatories to address the 26
consistency of Hydro One’s updated evidence on its proposed Joint Use Telecom Charge 27
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S2
Page 4 of 4
Witness: BOLDT John
with the methodology adopted by the OEB in the pole attachment report. This interrogatory 1
is not relevant to the scope defined by PO8. 2
3
2. Please refer to I-54-Rogers-S2 Q1 d). 4
5
3. Please refer to I-54-Rogers-S2 Q1 d). 6
7
4. Please refer to I-54-Rogers-S2 Q1 d). 8
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S3
Page 1 of 3
Witness: BOLDT John
Rogers Communications Interrogatory #S3 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
EB-2015-0141 Decision 8
Ex H1 - Joint Use Charges (31-Mar-2017) 9
Ex H1 - Joint Use Charges (07-Jun-2017) 10
Pole Rate Calculations (28-May-2018) 11
12
Interrogatory: 13
1. The table below was created using the data provided by Hydro One throughout this 14
proceeding and the EB-2015-0141 proceeding. We have calculated the percentage changes 15
since 2014. 16
2014
actuals
2015
actuals
2016
actuals
2017
actuals
2018
forecast
Total poles 1,575,195 1,571,384 1,562,984 1,564,628 1,566,272
Percentage change -- -0.2% -0.8% -0.7% -0.6%
Joint use poles 576,068
525,492 537,719
Percentage change --
-8.8% -6.7%
Gross book value $1,649 $1,783 $1,970 $2,067 $ 2,158
Percentage change -- 8% 19% 25% 31%
NEC $1,111 $1,245 $1,386 $1,456 $ 1,518
Percentage change -- 12% 25% 31% 37%
17
a) Please confirm the values provided in the above table, fill in the missing values and correct 18
any errors. 19
20
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S3
Page 2 of 3
Witness: BOLDT John
b) Since 2014, the total number of poles for 2017 and 2018 have decreased by 0.7% and 0.6% 1
respectively. Yet, for the same years, the gross book value per pole increased by 25% and 2
31%, and the NEC per pole increased by 31% and 37%. 3
4
Please explain how the number of poles can drop slightly but the NEC can increase by a wide 5
margin. What is driving the increase to net embedded cost? 6
7
In responding to this question, please provide all evidence and calculations that substantiate 8
your response. 9
10
Response: 11
1. a) 12
c) 13
2014
actuals
2015
actuals
2016
actuals
2017
actuals
2018
forecast
Total poles 1,575,195 1,571,384 1,562,984 1,564,628 1,566,272
Percentage change
relative to 20141 --
-0.2% -0.8% -0.7% -0.6%
Joint use poles 576,0682 573,780
3 513,265
4 525,492 537,719
Percentage change
relative to 20141 --
-0.40% -10.9% -8.8% -6.7%
Gross book value $1,649 $1,783 $1,970 $2,067 $ 2,158
Percentage change
relative to 20141 --
8% 19% 25% 31%
Net Embedded Cost $944.49 $1,058.065 $1,178.33
6 $1,237.22
7 $1,290.58
8
Percentage change
relative to 20141 --
12% 25% 31% 37%
14
1 Hydro One has clarified this description. 2 As filed in EB-2015-0141, on September 8, 2015, I-3-5(b) (VECC), page 2 of 3 3 As filed in EB-2017-0049, on February 12, 2018, I-51-VECC-119(a), page 2 of 2 4 As filed in EB-2017-0049, on February 12, 2018, I-54-Staff-260(b), page 2 of 2 5 As filed in EB-2017-0049, original filing on March 31, 2017, H1-02-03, page 103 of 112 6 As filed in EB-2017-0049, Blue Page Update filed on June 7, 2017, H1-02-03, page 103 of 112 7 As filed in OEB workform on May 28, 2018. 8 As filed in OEB workform on May 28, 2018.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S3
Page 3 of 3
Witness: BOLDT John
Gross Book Value is calculated as Acquisition Value, divided by the Total Number of Poles. Net 1
Embedded Cost is calculated as [(Acquisition Value-Accumulated Depreciation)/Total Number 2
of Poles]*85%. 3
d) As 4
b) Please refer to I-54-Staff-S3 (a). 5
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S4
Page 1 of 3
Witness: BOLDT John
Rogers Communications Interrogatory #S4 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Ex H1 - Joint Use Charges (07-Jun-2017) 8
Ex H1 - Joint Use Charges (26-Jun-2018) 9
Pole Rate Calculations (28-May-2018) 10
Pole Rate Work Form 11
EB-2015-0141 Decision 12
13
Interrogatory: 14
1. The table below was created using the data provided by Hydro One throughout this 15
proceeding and the EB-2015-0141 proceeding. We have calculated the change between 2017 16
and 2018. 17
Total Poles 2017 2018 Delta
30 223,024 218,682 -4,342
35 500,014 496,621 -3,393
40 432,907 437,937 5,030
45 233,978 237,925 3,947
50 and higher 163,968 165,657 1,689
Unknown 10,737 9,450 -1,287
Total 1,564,628 1,566,272 1,644
Joint Use Poles 2017 2018 Delta
30 48,615 48,775 160
35 143,681 146,379 2,698
40 151,467 156,110 4,643
45 108,754 112,277 3,523
50 and higher 71,930 73,139 1,209
Unknown 1,045 1,039 - 6
Total 525,492 537,719 12,227
ATTACHERS 2017 2018 Delta
Telecom 302,268 303,394 1,126
Overlashers - - -
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S4
Page 2 of 3
Witness: BOLDT John
Bell Canada 331,238 331,238 -
Streetlights 77,341 77,341 -
LDC Generators 14,263 14,267 4
Total 725,110 726,240 1,130
1
a) Please confirm the values provided in the table above. If there are any errors or omissions, 2
please correct them. 3
4
b) Between 2017 and 2018, you forecast that joint use poles (i.e., poles with third party 5
attachers) will increase by 12,227. However, the number of attachers will only increase by 6
1,130. Intuitively, this does not seem to correlate. How can joint use poles increase without a 7
corresponding increase in the number of attachers on those poles? Please explain, providing 8
all necessary supporting calculations and assumptions, how this is possible. 9
10
c) If LDC/Generator attachers always use joint use poles that are at least 50 feet, how is it 11
possible that, for 2017, there are 71,930 joint use poles that are 50 feet or higher, but only 12
14,263 LDC/Generator attachers? 13
14
What kinds of attachers are on the remaining 57,677 poles? 15
16
Please explain, with all necessary supporting calculations and assumptions. 17
18
d) If telecom attachers that overlash to the existing strand of other telecom attachers are 19
required to get a permit and pay the pole attachment charge, why do you show the number of 20
overlashers as zero? 21
22
Response: 23
a) Confirmed. 24
25
b) Hydro One’s pole data regarding Joint Use poles are constantly being updated by data 26
collection activities. Furthermore, the number of Joint Use poles can increase due to new 27
pole installations (for example new road crossing poles, new interspaced poles for new 28
services, asset sales and purchases, or line relocations and sustainment work that require 29
shorter spans). Because permits may not be updated and submitted when these new 30
attachments are made there is a lag in the database until the next inspection cycle. Please 31
refer to interrogatory I-VECC-S136 for a derivation of 12,227. 32
33
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S4
Page 3 of 3
Witness: BOLDT John
c) The remaining 57,677 poles are occupied by either telecom carriers, or streetlights. Where 1
Hydro One and a carrier are on the pole, poles 50 ft. or greater may be required due to terrain 2
changes, grading of poles, and/or ravines. 3
4
d) Hydro One does not separately track overlashers. The overlashers are tracked as a regular 5
telecommunications attachment. 6
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S5
Page 1 of 3
Witness: BOLDT John
Rogers Communications Interrogatory #S5 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Responses to Rogers Interrogatories 8
9
Interrogatory: 10
1. Please provide a detailed description of what process is required for Hydro One to replace a 11
joint use pole (i.e., a pole that has third party attachers on it). In your description, please 12
include: 13
Notification of attachers and timelines; 14
Design and engineering; 15
Make-ready work and apportionment of make-ready costs; 16
Cutover or transfer of Hydro One facilities and all attacher facilities to the 17
replacement pole. 18
19
2. In Rogers-04(1), we asked you to provide the number of joint use poles that were replaced 20
pursuant to a proactive pole replacement or other capital program (as opposed to replacement 21
as part of ongoing maintenance). You responded as follows: 22
23
Hydro One is unable to supply this information because we do not track to this level of 24
granularity. 25
26
a) If you do not track to this level of granularity, what do you track with respect to pole 27
replacements? 28
29
b) Please describe the reasons or the conditions under which you replace poles. 30
31
c) Which account codes are used to record pole replacement expenditures? 32
33
d) How do you identify which poles require replacement? 34
35
e) How do you budget which poles will be replaced in a given year and in future years? 36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S5
Page 2 of 3
Witness: BOLDT John
f) Please complete the following tables regarding the number of poles replaced for each year 1
stated. 2
3
Total poles replaced 4
5
Pole Height 2014 2015 2016 2017
<=25
30
35
35
40
45
50
55-60
Above 65
6
7
Joint use poles replaced 8
Pole Height 2014 2015 2016 2017
<=25
30
35
35
40
45
50
55-60
Above 65
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S5
Page 3 of 3
Witness: BOLDT John
3. In each of the years 2014 to 2017, how many poles were replaced as part of (1) ongoing pole 1
maintenance and (2) a proactive pole replacement program due to the requirements of Hydro 2
One, other LDCs or third party generators? 3
4
4. In each of the years 2014 to 2017, how many joint use poles that had telecom attachers were 5
replaced? 6
7
If your response is that Hydro One does not track to this level of granularity, please explain 8
how you can conduct pole replacements without knowing who is on the poles and arranging 9
the transfer to the replacement pole. 10
11
Response: 12
1. Please refer to I-54-Rogers-S2 Q1 d). 13
14
2. a) – b), d) – f) Please refer to I-54-Rogers-S2 Q1 d). 15
16
c) USoA 1830 (Dx Poles, Towers and Fixtures) is used to record pole replacement costs 17
associated with the poles and fixtures (crossarms, brackets, down guys, etc.). 18
19
USoA 1835 is used to record expenditures associated with overhead conductors and 20
devices (i.e. insulators, wire if needed). 21
22
3. - 4. Please refer to I-54-Rogers-S2 Q1 d). 23
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S6
Page 1 of 4
Witness: BOLDT John
Rogers Communications Interrogatory #S6 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Responses to Rogers Interrogatories 8
9
Interrogatory: 10
1. Please complete and confirm the entries in the following table using the most current 11
information available (2017). Please enter actual numerical values and not references to OEB 12
orders or evidentiary documents. 13
14
Attacher
Qty (end
of 2017)
Current
Rate
2017
Rate
2018
Rate
Telecom attachers
Bell pole-sharing (Full) N/A N/A
Bell pole-sharing (Clearance)
Other Telecom (Full) $41.28 $47.43
Other Telecom (Clearance) $30.96 $47.43
Generator Telecom $41.28 $47.43
Total Telecom
Other attachers
Generator power facilities $85.25
LDC power facilities $85.25
Streetlights $2.04 $2.04
Total Other
Wireless attachers
Bell antennas and wireless equip.
Other antennas and wireless equip
Total Wireless
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S6
Page 2 of 4
Witness: BOLDT John
2. In your response to Rogers-05(1) regarding the number of Bell clearance poles, you 1
responded with “N/A”. What does this mean? Is it that Bell does not have any clearance 2
poles? Or is it that Bell clearance poles are included in a different row in the table? 3
Regardless of the answer, please provide the number of clearance poles used by Bell. 4
5
3. In Rogers-05(2), Rogers-05(8)(b) and Rogers-05(8)(c), we asked you why streetlights 6
continue to pay only $2.04 when compared to other pole attachers, and whether Hydro One 7
was under-recovering its costs and therefore requiring the ratepayers to subsidize these 8
attachments. You responded as follows: 9
10
For streetlight rates of $2.04 per year, $2.04 is a rate that was negotiated over 25 years ago 11
for a light to be attached to a distribution 20 pole. Over the years, municipalities have 12
lobbied the provincial government for the right to charge utilities for poles occupying their 13
municipal right of ways. If Hydro One were to increase that rate, there is a risk that 14
municipalities may get the right to charge for poles on right of ways, which would 15
significantly increase the burden on the Hydro One ratepayer. 16
17
a) To your knowledge, when was the last time a municipality lobbied the provincial government 18
for the right to charge utilities for their poles on municipal rights-of-way? Please provide 19
evidence of such lobbying efforts. 20
21
b) You state that if Hydro One were to increase the streetlight rate, there is a risk that 22
municipalities may obtain the right to charge for poles on their rights-of-way. Please describe 23
the nature and quantum of this “risk”. What would have to be done from a legislative point of 24
view to make this happen? 25
26
c) You state that if municipalities get the right to charge for poles on municipal rights-of-way, 27
this would significantly increase the burden on Hydro One ratepayers. 28
29
i. What do you mean by “significantly”? 30
31
ii. Have you actually assessed the quantum of this risk that this may impose on 32
residential ratepayers? If so, what is that value? How much more would 33
residential ratepayers end up paying? 34
35
d) Provide a list of the top ten municipalities that are using Hydro One poles for streetlights and 36
show how many poles each municipality utilizes. Please use 2017 numbers. 37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S6
Page 3 of 4
Witness: BOLDT John
4. We understand that Bell and Telus have been very active in the deployment of small cell 1
antennas in the Province of Ontario, including on utility poles. 2
3
a) Has Hydro One entered into any agreements with Bell or other telecoms to allow them to 4
attach antennas or other wireless equipment to Hydro One’s joint use poles, now or in the 5
future? 6
7
b) What is the pole attachment rate under these agreements? 8
9
5. In Rogers-05(2), we asked how Hydro One intends to treat the revenues it may receive from 10
wireless attachments, and whether it would adjust the wireline telecom pole attachment rate 11
to reflect the additional revenues derived from these new pole attachments. You responded as 12
follows: 13
14
Wireless attachment revenue will not be used to reduce the regulated amount for wireline 15
attachments. It will be reported as external revenue, which will reduce Hydro One’s 16
distribution rate revenue requirement. 17
18
a) Does this statement still reflect your views? 19
20
b) If you do not intend to adjust the wireline attachment rate, please provide a rationale for this 21
decision and explain why it would still be reasonable from a rate-making perspective. 22
23
c) Has this treatment of wireless attachment revenues been approved by the OEB? What makes 24
you think that the Board would approve this approach? 25
26
Response: 27
1. 28
Attacher
Qty (end
of 2017)*
Current
Rate
2017
Rate
2018
Rate
Telecom attachers
Bell pole-sharing (Full) 298,114 N/A N/A N/A
Bell pole-sharing (Clearance) 33,124 N/A N/A N/A
Other Telecom (Full) 274,463 $41.28 $41.28 $47.691
1 Correction to Rogers Interrogatory. See I-54-VECC-S134(c).
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S6
Page 4 of 4
Witness: BOLDT John
Attacher
Qty (end
of 2017)*
Current
Rate
2017
Rate
2018
Rate
Other Telecom (Clearance) 24,122 $30.96 $30.96 $47.691
Generator Telecom 3,683 $41.28 $41.28 $47.691
Total Telecom 633,506
Other attachers
LDC & Generator power facilities 14,263
Sliding
Scale, 10
ft. of space
= $47.82
Sliding
Scale, 10
ft. of
space =
$47.82
$85.25
Streetlights 77,341 $2.04 $2.04 $2.04
Total Other 725,110
Wireless attachers
Bell antennas and wireless equip. 0 N/A N/A N/A
Other antennas and wireless equip 0 N/A N/A N/A
Total Wireless 0
*The attacher numbers submitted in the first column (“Qty. (end of 2017)) represent the volumes at the beginning of 2017 as 1
these would have been used for billing in 2017. 2
3
2. The clearance poles were included in the total number of Bell attachments in Rogers 5(1). 4
The number of Bell attachments are separated in the table above. 5
6
3. - 5. Please refer to I-54-Rogers-S2 Q1 d). 7
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S7
Page 1 of 5
Witness: BOLDT John
Rogers Communications Interrogatory #S7 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Pole Rate Calculations (28-May-2018) 8
Pole Rate Work Form 9
EB-2015-0141 Decision 10
Pole Attachment Report 11
Responses to Rogers Interrogatories 12
13
Interrogatory: 14
1. In your response to Rogers-06(1), you stated that no pole replacement costs had been 15
included in Pole Maintenance Expenses. You also stated that poles replaced at the request of 16
a third party are capitalized at the cost, less the third party’s contribution, and the third 17
party’s contribution is inserted into Account 1830 as a negative value. 18
19
a) Are these responses still valid? 20
21
b) Please provide a page from your audited financial statements or other suitable documents that 22
demonstrates this practice of including a third party’s contribution as a negative value in 23
Account 1830. 24
25
2. In your response to Rogers-06(2), you confirmed that power assets and other equipment 26
owned or operated by Hydro One that are located on poles owned by other parties such as 27
Bell are included in Account 1830, and therefore the calculation of NEC. 28
29
We then asked you to provide a value for these assets (or your best estimate) for the years 30
2015, 2016 and 2017. You responded that Hydro One does not specifically track the cost of 31
these fixtures separately in Account 1830. 32
33
a) If you do not “specifically track the cost of these fixtures separately”, then please explain 34
what you do track with respect to these fixtures. 35
36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S7
Page 2 of 5
Witness: BOLDT John
b) If you still claim to have no viable numbers, please provide your best estimate. In doing so, 1
please show how the number was obtained with supporting calculations, documents, 2
assumptions and rationale. Who from Hydro One (including their title and job description) 3
prepared this estimate? 4
5
c) Do you agree that these costs should not be included in the common costs of the pole that are 6
shared with the telecom attacher? 7
8
d) Please describe what fixtures and other equipment Hydro One has installed on Bell-owned 9
poles. 10
11
e) How many Bell-owned poles does Hydro One use for its power facilities? Please provide 12
your answer for each of the years 2014-2018. 13
14
3. The following questions have to do with make-ready costs paid by telecom attachers. 15
16
a) Please describe the process under which a prospective telecom attacher is required to pay 17
make-ready costs to attach to a joint use pole. 18
19
b) In Rogers-06(2)(a), we asked you to provide the value of make-ready costs paid by telecom 20
attachers in each of the years 2015-2017. You responded that you do not “track to this level 21
of granularity”. 22
23
Please explain how it is that you do not have records of make-ready costs paid by telecom 24
attachers when you have to invoice them for such costs? What records of make-ready costs 25
do you maintain? 26
27
c) In your response to Rogers-06(2)(b), you asserted that telecom make-ready costs are 28
included as a negative value in Account 1830. Please provide evidence from your 2017 29
audited financial statements that demonstrates this practice. 30
31
4. In your response to Rogers-06(4), you confirmed that, unless a common anchor is used, a 32
telecom attacher is responsible for the costs of its own guying and anchors. 33
34
a) Is this response still valid? 35
36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S7
Page 3 of 5
Witness: BOLDT John
b) Are the costs of guying and anchoring for all poles included in Account 1830? What is the 1
value of these costs for the years 2017 and 2018. 2
3
c) If your response is that you do not track to this level of granularity, then please provide an 4
estimate, including all assumptions and rationale to support the estimate. Who from Hydro 5
One, including their title and job description, prepared this estimate? 6
7
d) If a telecom attacher is responsible for its own guying and anchors, why should guys and 8
anchors be included as part of the NEC for the purpose of determining the pole attachment 9
rate? Shouldn’t these fall under pole-specific costs? Explain why or why not. 10
11
5. In your response to Rogers-07(1), you stated that, over the last 10 years, 3,356 poles were 12
replaced to accommodate the facilities of generators. 13
14
a) How many poles were replaced for this purpose in each of the years 2014 to 2017? 15
16
b) How many poles do you expect to replace for this purpose in 2018? 17
18
c) What is the value of the capital contributions provided by the generators for these poles in 19
each of the years 2014 to 2017? 20
21
d) You also stated that these capital contributions were included as a negative value in Account 22
1830. Please provide evidence from your audited financial statements that demonstrate this 23
transaction. 24
25
6. Hydro One has chosen to complete the OEB’s Work Form, which allows an LDC to input its 26
“Distributor Specific Inputs”. Hydro One has done this for all the cost inputs and number of 27
poles and attachers. Yet, despite the Work Form having a cell to input a specific percentage 28
for power-only assets, you have simply chosen to use 15%. 29
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S7
Page 4 of 5
Witness: BOLDT John
In the Pole Attachment Working Group (PAWG) proceeding leading up to the Pole 1
Attachment Report, Hydro One provided a detailed “proxy” for calculating the percentage of 2
power-specific assets on joint use poles. This proxy methodology came up with a ratio of 3
17%, which was then whittled down to 15% to take into account certain extraordinary 4
expenses. (It should be noted that the calculations and assumptions in this proxy were not 5
challenged or substantiated.) 6
7
Given that Hydro One has now decided to seek a pole attachment rate based on its 8
distributor-specific factors, please provide a detailed analysis that calculates the power-9
specific asset percentage, using a methodology similar to the proxy provided by Hydro One 10
in the PAWG proceeding. (Rogers reserves the right to review and challenge whatever Hydro 11
One prepares, whether through additional interrogatories or a technical conference.) 12
13
7. Does Account 1830 include structures such as towers that are not poles? If so, what is the 14
2017 and 2018 (forecast) values of these assets? 15
16
Response: 17
1. a) The amounts capitalized in USoA 1830 are the costs, minus the third party contributions. 18
19
b) All Hydro One plant and equipment is recorded at original cost, net of customer 20
contributions, and any accumulated impairment losses. The cost of additions, including 21
betterments and replacement asset components, is included on the Consolidated Balance 22
Sheets as property, plant and equipment1. 23
24
2. a) USoA 1830 tracks all Hydro One owned poles and fixtures. 25
26
b) Please refer to I-54-Rogers-S2 Q1 d). 27
28
c) Yes. The OEB methodology includes a 15% reduction of Net Embedded Costs to remove 29
power specific assets. 30
31
d) The types of fixtures and other equipment that Hydro One has installed on Bell-owned 32
poles are the same that Hydro One has attached to our own poles. 33
34
e) Please refer to I-54-Rogers-S2 Q1 d). 35
1 Interrogatory I-01-SEP-001 Attachment 1, page 9.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S7
Page 5 of 5
Witness: BOLDT John
3. Please refer to I-54-Rogers-S2 Q1 d). 1
2
4. 3
a) Yes 4
5
b) Yes, the costs of guying and anchoring for all poles are included in USoA 1830. Hydro 6
One is unable to distinguish these costs in USoA 1830. 7
8
c) Following the OEB’s accounting guidelines, Hydro One is unable to distinguish these 9
costs in USoA 1830. 10
11
d) Guying and anchoring costs are included as fixtures in USoA 1830. In following the 12
OEB’s workform, Net Embedded Cost is reduced by 15% to account for these fixtures. 13
14
5. a) - c) Please refer to I-54-Rogers-S2 Q1 d). 15
16
d) Please refer to 1 b) above. 17
18
6. Please refer to I-54-Rogers-S2 Q1 d). 19
20
7. Distribution steel towers are included in USoA 1830. The total value of these assets is below 21
the materiality threshold. 22
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S8
Page 1 of 3
Witness: BOLDT John
Rogers Communications Interrogatory #S8 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Ex H1 - Joint Use Charges (26-Jun-2018) 8
Pole Rate Calculations (28-May-2018) 9
Pole Rate Work Form 10
11
Interrogatory: 12
1. In all versions of your calculations for the LDC/Generator pole attachment rate, you applied 13
Hydro One’s productivity factor to a variety of components of that rate, including: 14
the CPI adjustment to determine the rates from 2018 to 2022; 15
loss of productivity costs; and 16
administrative costs. 17
18
a) How come you use a productivity factor for the pole attachment rate for LDC/Generator 19
attachers but not for telecom attachers? It is, after all, the same pole. Please explain this 20
inconsistency. 21
22
b) If your answer is that, in the Pole Attachment Report, the OEB determined that there 23
should be no productivity factor for telecom attachers, then please explain why this 24
inconsistency in rate-making practice should exist and should not offend regulatory 25
principles. 26
27
2. When calculating the 2018 LDC/Generator pole attachment rate, you used 2016 actuals for 28
NEC to derive a 2017 rate. You then adjusted the 2017 rate with CPI and your productivity 29
factor in order to come up with a 2018 rate. Yet, in calculating the 2018 pole attachment rate 30
for telecom attachers, you used forecast numbers for 2018. 31
32
a) Please confirm that, in the EB-2015-0141 Decision, the OEB directed that Hydro One should 33
use historical, and not forecast, numbers when calculating the telecom pole attachment rate. 34
If this is not the case, then provide your understanding of this decision. 35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S8
Page 2 of 3
Witness: BOLDT John
b) Please confirm that the Pole Attachment Report does not require an LDC to use forecast 1
costs for the telecom pole attachment rate. If this is not the case, then provide your 2
understanding of this report. 3
4
c) Please explain why the pole attachment rate for LDC/Generator attachers uses historical 5
numbers (actuals) but the rate for telecom attachers uses forecast figures? It is, after all, the 6
same pole. Please explain this inconsistency. 7
8
d) If your answer is that the Pole Rate Work Form includes a column for 2018 forecast 9
numbers, then please explain why this inconsistency in rate-making should exist and should 10
not offend regulatory principles. 11
12
3. In Figure 1 at p.106 of Ex H1 - Joint Use Charges (26-Jun-2018), you demonstrate that 13
each of the two power attachers, Hydro One and the LDC/Generator, is responsible for 14
38.6% of the space on a 50 foot pole. Combined, the two power attachers are responsible for 15
77.2% of the pole and the associated common costs. This leaves 22.8% for the telecom 16
attachers. 17
18
However, the methodology you use for telecom attachers assigns 31.2% of the space (and 19
31.2% of the common costs) to the telecom attachers. As we see it, for these kinds of poles, 20
Hydro One is recovering at least 108.4% of its common costs. 21
22
Please confirm our understanding and explain why Hydro One is over-recovering its 23
common costs by 8.4% and explain why the telecom attacher allocation factor for these poles 24
should not be 22.8%. If you do not agree, please explain why. 25
26
Response: 27
1. a) Hydro One has applied the OEB’s methodology for determining the telecom Joint Use 28
rate. 29
30
b) Please refer to I-54-Rogers-S2 Q1 d). 31
32
2. a) Please refer to I-54-Rogers-S2 Q1 d). 33
34
b) The OEB workform uses 2018 forecasted costs to determine the current pole 35
attachment charge. 36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S8
Page 3 of 3
Witness: BOLDT John
c) Hydro One has applied the OEB’s methodology for determining the telecom Joint Use 1
rate. 2
3
d) Please refer to I-54-Rogers-S2 Q1 d). 4
5
3. Please refer to I-54-Rogers-S2 Q1 d). 6
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S9
Page 1 of 2
Witness: BOLDT John
Rogers Communications Interrogatory #S9 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Pole Rate Calculations (28-May-2018) 8
Pole Rate Work Form 9
Pole Attachment Report 10
Ex H1 - Joint Use Charges (26-Jun-2018) 11
12
Interrogatory: 13
1. In the PAWG Proceeding, two LDCs provided estimates of what portion of pole maintenance 14
costs should be allocated to telecom attachers. Hydro One, with a pole population of roughly 15
1.5 million poles, proposed 5% and Hydro Ottawa, with just over 3% of Hydro One’s pole 16
population, proposed 92%. In the absence of any additional data and, without an exploration 17
of why this huge disparity existed, the Board determined that it would be appropriate to use 18
the median or average of 5% and 92%, to come up with 48.5%. 19
20
a) Please confirm if that is also your understanding of how the Board came up with a figure of 21
48.5%. 22
23
b) If this is not your understanding, provide what your understanding is. 24
25
2. Hydro One has chosen to complete the OEB’s Work Form, which allows an LDC to input its 26
“Distributor Specific Inputs”. Hydro One has done this for all the cost inputs, as well as the 27
number of poles and attachers. Yet, despite the Work Form requiring a specific input for 28
allocation of pole maintenance costs, Hydro One has chosen to use 48.5%. 29
30
a) Please explain why Hydro One has used 48.5% when it calculated and proposed 5% in the 31
PAWG Proceeding. 32
33
b) Please substantiate why you believe 48.5% is the appropriate number in light of your 5% 34
calculation. 35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S9
Page 2 of 2
Witness: BOLDT John
3. At page 109 of Ex H1 - Joint Use Charges (26-Jun-2018), you calculate pole maintenance 1
cost for LDC/Generator attachers, arriving at a figure of $4.08 per pole. Yet, in this 2
proceeding, you are proposing $7.13 for telecom attachers. 3
4
Please explain why you think it is reasonable for telecom attachers to pay a larger share of 5
the pole maintenance costs than the LDC/Generators when the LDC/Generators take up more 6
space on a pole. 7
8
4. Please demonstrate how you determined the 5% allocation in the PAWG Proceeding, 9
showing all calculations and assumptions. 10
11
5. Please provide a detailed calculation for Pole Maintenance Expenses, similar to what you 12
have provided in your calculations for the LDC/Generator pole attachment rates. 13
14
Response: 15
1. Please refer to I-54-Rogers-S2 Q1 d). 16
17
2. 18
a) Hydro One has applied the OEB’s methodology and pole maintenance cost allocation 19
factor for determining the Telecom Joint Use rate. 20
21
b) Please refer to I-54-Rogers-S2 Q1 d). 22
23
3. Please refer to I-54-Rogers-S2 Q1 d). 24
25
4. Please refer to I-54-Rogers-S2 Q1 d). 26
27
5. Hydro One has applied the OEB’s methodology to pole maintenance costs, Account 5120, 28
and presented these costs in the OEB work form. 29
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S10
Page 1 of 2
Witness: BOLDT John
Rogers Communications Interrogatory #S10 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Pole Rate Calculations (28-May-2018) 8
9
Interrogatory: 10
In your Admin Costs of $1.59 per pole, you include $1,109,258 for “Joint Use Staff Specific 11
Labour”. 12
13
1. Please describe in detail each of the applicable staff, including their job title and the functions 14
they perform in their roles in support of these Admin Costs. 15
16
2. In addition to telecom attachments, do these staff members perform administrative work in 17
respect of LDC/Generator attachments, Bell attachments (under pole-sharing arrangements) 18
and streetlights? 19
20
3. In the years 2015, 2016 and 2017, how many permits did they review and issue for: 21
22
a) Telecom attachments that are required to pay the pole attachment rate; 23
24
b) LDC/Generator attachments; 25
26
c) Bell attachments (under pole-sharing arrangements); and 27
28
d) Streetlights. 29
30
Response: 31
1. The team consists of one clerk, three Joint Use officers, a supervisor, and a senior manager. 32
The team monitors approximately 580 agreements, creates memos, resolves disputes, trains 33
staff, monitors permits, issues invoices, monitors accounts receivables, performs Regulation 34
22/04 audits, works with joint use standards, distribution rate filings and, writes and 35
negotiates new agreements. 36
37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S10
Page 2 of 2
Witness: BOLDT John
2. Yes. 1
2
3. The team does not review and issue permits. This work is performed by field staff. 3
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S11
Page 1 of 2
Witness: BOLDT John
Rogers Communications Interrogatory #S11 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Pole Rate Calculations (28-May-2018) 8
9
Interrogatory: 10
1. For your Loss of Productivity Costs of $3.20 per pole, you use $2,321,078 for 11
labour and vehicles associated with trouble calls dispatched on behalf of telecom attachers. 12
13
a) In 2017, how many, and what percentage, of these trouble calls were associated with Bell 14
attachments (under pole-sharing arrangements)? 15
16
b) You describe numerous activities (Labour Types) required in connection with these trouble 17
calls, such as DOMC, RLM and Clerical – Scheduling/CIS. For each Labour Type in this 18
table, please describe what the acronyms mean and what activities are undertaken. 19
20
2. You state that the Loss of Productivity costs are based on 2017 hours and 2018 Labour 21
Dollars. What is the difference between 2017 Labour Dollars and 2018 Labour Dollars? How 22
were 2018 Labour Dollars determined? 23
24
Response: 25
1. 26
a) Trouble calls related to telecom wires are grouped together; the telecom attacher is not 27
recorded. 28
29
b) DOMC stands for Distribution Operations Maintenance Centre. The staff in the DOMC 30
will receive trouble calls from the customers, and dispatch the crews to address the 31
trouble call. 32
RLM stands for Regional Line Maintainers. They respond to the trouble call. 33
Clerical – Scheduling/CIS (Customer Information System) staff complete the paperwork 34
after the call. 35
36
37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S11
Page 2 of 2
Witness: BOLDT John
2. Please see the table below for a comparison of the 2017 and 2018 fully burdened labour 1
rates. Please refer to I-54-VECC-134(c) for the correction to the Loss of Productivity cost 2
from $3.20 per pole, per attacher, to $3.22 per pole, per attacher. 3
4
Resource Type 2017 Labour Rate 2018 Labour Rate Increase in 2018
DOMC Staff $124.00 $125.00 $1.00
Regional Line
Maintainer* $123.00 $124.00 $1.00
Clerical –
Scheduling/CIS* $124.00 $125.00 $1.00
*The overtime rates are applied at 140% of the regular hours rates. 5
6
2018 Labour rates were determined based on standard labour rates for the resource doing the 7
work. 8
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Rogers-S12
Page 1 of 1
Witness: BOLDT John
Rogers Communications Interrogatory #S12 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Responses to Rogers Interrogatories 8
9
Interrogatory: 10
1. Will the proposed pole attachment rate for Hydro One apply to Norfolk Power, Haldimand 11
County Hydro and Woodstock Hydro? If not, what pole attachment rate will apply to these 12
three LDCs and when will it come into effect? 13
14
2. Have you done any kind of analysis to demonstrate that these three LDCs share substantially 15
similar pole costs and number or telecom attachers as Hydro One has used in this 16
proceeding? 17
18
Response: 19
1. Hydro One’s proposed rate in this application will apply to the Acquired Utilities when they 20
are integrated in 2021. 21
22
Hydro One will apply the OEB’s province-wide wireline pole attachment charge as set out in 23
its Accounting Guidance on Wireline Pole Attachment Charges issued July 20th
, 2018 to the 24
Acquired Utilities’ Telecom customers, until their integration in 2021. 25
26
2. No. 27
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S1
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S1 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 1; 8
HONI_SUB_Pole Attachment Workform_20180528, Tab 3. Direct Costs 9
10
Interrogatory: 11
Preamble: 12
13
In Tab 3 – Direct Costs of the Pole Attachment Workform, Table 4 - Administration Costs, 14
Hydro One has entered zero dollars for both Direct Labour Costs related to billing and permit 15
processing costs as well as for Inventory / direct purchases. 16
17
a) Please confirm there are no costs related to these sub accounts for all joint-use poles. 18
19
b) Are any costs related to these sub accounts being directly billed to carriers? 20
21
Response: 22
a) Confirmed. 23
24
Billing Costs: These costs are part of the Joint Use team’s labour costs (Other Support 25
Services Costs). Included is the Business Support Clerk, who verifies and releases bills for 26
printing and mailing. The clerk also monitors Account Receivables and handles 27
communication about invoices and bill collection. Hydro One’s third party accounts 28
receivable contractor prints the bills, mails them to the customer and enters the payments into 29
the system once received. The work associated with the contractor is minimal, and is part of a 30
larger contract, and therefore excluded from the calculation of the Joint Use rate. 31
32
Permit Processing Costs: The design technician work and permit processing costs would be 33
billed directly to the carrier 34
35
Inventory/Direct Purchases: The inventory administration costs for the provincial Joint Use 36
team are immaterial. 37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S1
Page 2 of 2
Witness: BOLDT John
If there are any direct purchases associated with work in the field, those costs would be billed 1
directly to the carrier. 2
3
b) If there are any direct purchases associated with work in the field, those costs would be billed 4
directly to the carrier. 5
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S2
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S2 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 1; 8
HONI_SUB_Pole Attachment Workform_20180528, Tab 3. Direct Costs 9
10
Interrogatory: 11
Preamble: 12
13
In Section 1.0 of the Supplemental Explanation, page 1, Hydro One provided the breakdown of 14
Admin Costs of $1.59 per attacher, per pole as follows: 15
16
GIS Tracking (Joint Use Database Maintenance): 17
(2018 Joint Use Database enhancement costs = $38,378) + (Annual maintenance costs = 50 18
hours x $181/hour = $9,050) = $47,428 19
20
Joint Use Staff Specific Labour: $1,109,258.50 21
22
Total Administration Costs = $47,428+$1,109,258.50 = $1,156,686.50 23
24
Administration Cost Per Pole, Per Attacher = (2018 Total Administration Costs/Qty. of Joint Use 25
Poles Extrapolated for 20,181)/2018 Number of Attachers Per Pole 26
27
Administration Cost Per Pole, Per Attacher = ($1,156,686.50/537,719)/1.35 = $1.59 28
29
a) Please confirm that the Joint Use Database enhancement costs of $38,378 are one-time costs. 30
What types of activities are included as part of Hydro One’s GIS tracking costs? 31
32
b) Please confirm whether there are additional Joint Use Database enhancements planned in the 33
5-year period. If yes, how will Hydro One take this cost increase into account going forward? 34
35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S2
Page 2 of 2
Witness: BOLDT John
c) Hydro One has submitted a cost for Joint Use Labour of $1,109,258.50. Please provide more 1
detail on the types of labour activities that have been completed that are directly related to 2
carrier pole attachments. 3
4
d) Could any of the labour activities identified above be considered “make ready”? 5
6
e) Why does Hydro One consider its Administrative Cost to be reasonable? 7
8
Response: 9
a) The Joint Use Database enhancement costs of $38,378 are one-time costs for 2018. There 10
are also annual costs associated with the maintenance of a database. 11
12
Hydro One does not track GIS costs separately for Joint Use Poles. As submitted in Hydro 13
One’s May 28th
, 2018 Supplemental Explanation, the Joint Use Database costs have been 14
included under the GIS Tracking Cost. 15
16
b) No, however future enhancements to the database may be made where an update to the 17
system is required. 18
19
c) The labour that has been submitted is the labour associated to the overall provincial Joint Use 20
program. The team monitors agreements, creates memos, resolves disputes, trains staff, 21
monitors permits, issues invoices, monitors accounts receivables, performs Regulation 22/04 22
audits, works with joint use standards, distribution rate filings and writes and negotiates new 23
agreements. 24
25
d) No. 26
27
e) Hydro One has applied the OEB’s methodology using the OEB workform to determine its 28
Administration Cost. Hydro One has captured its Joint Use Database costs and total labour 29
costs that are not collected through make ready work, as make ready work costs are billed 30
directly to the third party. 31
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S3
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S3 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, pages 1-2; 8
Evidence Updated: 2017-0607, Exhibit H1, Tab 2, Schedule 3, page 103 9
10
Interrogatory: 11
Preamble: 12
13
In Section 3.0 of the Supplemental Evidence, Hydro One provided the calculation of the 2018 14
Net Embedded Cost: 15
16
Net Embedded Cost (NEC) of $1,290.58 = {[2018 Forecasted Year End Acquisition Value, as 17
stated in D2-01-02-01, Page 5 of 5, USoA 1830, Cost, Closing Balance ($3,380,110,026.80) – 18
2018 Forecasted Year End Acquisition Value, as stated in D2-01-02-01, Page 5 of 5, USoA 19
1830, Accumulated Depreciation, Closing Balance ($1,002,000,428.80) = 20
$2,378,109,598.00]/Qty. of Poles Extrapolated for 2018 (1,566,272)}* 85% 21
22
And in Section 1, Hydro One provided the calculation of the 2016 Net Embedded Cost: 23
24
2016 Net Embedded Cost (NEC) of $1,178.33 = {[2016 Year End Acquisition Value, 25
($3,079,485,436) – 2016 Accumulated Depreciation ($912,770,751) = $2,166,714,685]/Qty. of 26
Poles December 31, 2016 (1,562,984)}* 85% 27
28
a) The Net Embedded Cost has increased by 9.5% (by staff’s calculations, $1,290.58 - 29
$1,178.33 = $112.25 increase). Please describe the factors that are driving this increase 30
which ultimately drives higher carrying charges. 31
32
b) Given Hydro One’s pole replacement programs over the next 5 years and planned mergers 33
and acquisitions of smaller utilities, does Hydro One anticipate similar year-over-year 34
increases in the Net Embedded Cost per pole? 35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S3
Page 2 of 2
Witness: BOLDT John
c) If Hydro One’s Net Embedded Cost does escalate at the same rate over the next 5 years, 1
would the annual inflationary adjustment to the Hydro One’s new Pole Attachment charge 2
cover this increase? 3
4
Response: 5
a) Over the two year period (2016 to 2018), the driving factor for the increase has been the 6
addition of capital costs related to pole replacements (less the customer contribution). As 7
older poles are replaced year over year, the cost of the replacement poles are capitalized 8
within USoA 1830. 9
10
b) USoA 1830 will continue to reflect Hydro One’s capital investments. The impact of a merger 11
and acquisition on Hydro One’s Net Embedded Cost per pole would depend on the value of 12
the acquired utility’s USoA 1830 and the number of poles. 13
14
c) To the extent that costs inflate greater than the annual inflationary adjustment, the new pole 15
attachment charge would not cover the total increase. 16
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S4
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S4 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 2; 8
Updated Evidence: 2017-0607, Exhibit H1, Tab 2, Schedule 3, page 103 9
10
Interrogatory: 11
Preamble: 12
13
In Section 4.0 of the Supplemental Explanation page 2, Hydro One provided Depreciation Cost 14
of $33.45: 15
16
4.0 Depreciation Cost of $33.35 17
18
Depreciation Rate = 1.82% 19
Depreciation Rate = 1/Hydro One’s Useful Life of Poles (as stated in C1-06-01, Attachment 20
1, Page 22) = 1/55 = 1.82% 21
22
and Updated Evidence: 2017-06-07, Exhibit H1, Tab 2, Schedule 3, page 103 Hydro One 23
provided: 24
25
2016 Depreciation Cost of $28.47 = [2016 Year End Acquisition Value 26
($3,079,485,436)*HONI Depreciation Rate (1.7%)*85% allocation factor remove any pole-27
associated assets]/Qty. of Poles (1,526,984). 28
29
In the HONI_SUB_Pole Attachment Workform_20180528, Tab Appendix Provincial Rate, the 30
other utilities that participated in the Pole Attachment Consultation had higher depreciation rates. 31
32
Hydro One’s supplemental evidence uses a depreciation rate based on a useful pole life of 55 33
years. In its evidence from 2017 noted above, Hydro One uses a 60 year pole life. 34
35
a) Please confirm that Hydro One is requesting that depreciation expense be calculated from a 36
useful life of 55 years. 37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S4
Page 2 of 2
Witness: BOLDT John
b) Please provide rationale for the decrease in the useful lives of poles from 60 years to 55 1
years. 2
3
c) Does Hydro One have any evidence to show that joint-use poles have a shorter pole life 4
expectancy because of additional stresses placed on them because of third party attachments? 5
Should joint-use poles be depreciated at a different rate than dedicated power poles? 6
7
d) Will Hydro One’s planned pole replacement program impact the average pole useful life that 8
it assumes? 9
10
e) Does pole size impact the useful life of Hydro One poles? Has this been factored into the 11
average pole life that Hydro One assumes for its pole population? 12
13
f) What impact does geographical location have on pole life? Has this been factored into the 14
average pole life that Hydro One assumes for its pole population? 15
16
g) Are Hydro One poles more susceptible to storm damage than other utilities because of their 17
average age? 18
19
Response: 20
a) Confirmed. 21
22
b) Hydro One has followed the OEB methodology in the OEB’s workform, Hydro One inputted 23
the useful life of poles at 55 years found in Exhibit C1-06-01, Attachment 1 page 22. Hydro 24
One did not use a useful life of 60 years previously. 25
26
c) Please refer to I-54-Rogers-S2 Q1 d). However, for the benefit of the Board and the parties, 27
Hydro One can advise that it did not make any evidentiary submissions that could assist with 28
this interrogatory. 29
30
d) Changes to Hydro One’s pole replacement program that impact the expected useful service 31
life of poles, may impact depreciation rates. Hydro One would need to engage its external 32
depreciation consultant, Foster Associates, to review the program changes and assess any 33
impact on rates. 34
35
e) – g) Please refer to I-54-Rogers-S2 Q1 d). 36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S5
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S5 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 2 8
HONI_SUB_Pole Attachment Workform_20180528, Tab Appendix Provincial Rate. 9
10
Interrogatory: 11
Preamble: 12
13
In Section 6.0 of the Supplemental Evidence, Hydro One provided the calculation of Capital 14
Carrying Cost of $96.66: 15
16
6.0 Capital Carrying Cost of $96.66 = 2018 Forecasted Net Embedded Cost as calculated in 17
Line 3 above ($1,290.58) * 2018 Before Tax Weighted Average Cost of Capital (WACC) 18
(7.49%) 19
20
a) Please provide the breakdown of the calculation of the pre-tax WACC, and a comparison of 21
the changes in the pre-tax WACC for the bridge and test years. 22
23
b) Why is Hydro One’s pre tax WACC higher than the WACC of other utilities that participated 24
in the pole attachment consultation? (Please reference File: HONI_SUB_Pole Attachment 25
Workform_20180528, Tab Appendix Provincial Rate) 26
27
c) Does Hydro One anticipate this rate decreasing or increasing significantly in the next five 28
years or remaining approximately the same? 29
30
Response: 31
a) The pre-tax WACC is calculated as follows: 32
Pre-tax WACC = (Target Long Term Debt Ratio * Medium & Long Term Borrowing Rate) 33
+ (Target Short Term Debt Ratio * Short Term Borrowing Rate) + (Target Equity Ratio * 34
Target Before Tax Return on Equity) 35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S5
Page 2 of 2
Witness: BOLDT John
The rates below, also filed in EB-2017-0049, Exhibit Q, Tab 1, Schedule 1, Section 1.3, Table 8, 1
show the Hydro One rates for 2018: 2
3
Distribution WACC 2017 2018
Rates
Short term borrowing rate 1.76% 2.29%
Medium & Long Term Borrowing Rate 4.43% 4.47%
Allowed Return on Equity 8.78% 9.00%
Capital structure
Target Short-term debt ratio 4.00% 4.00%
Target Long-term debt ratio 56.00% 56.00%
Preferred shares 0.00% 0.00%
Target Equity Ratio 40.00% 40.00%
Proxy Income Tax Rate 26.50% 26.50%
Pre-tax WACC 7.33% 7.49%
4
The 2018 target pre-tax Return on Equity is calculated as follows: Allowed Return on Equity/(1-5
Proxy Income Tax Rate) = 9.00%/(1-26.50%) = 9.00%/73.50% = 12.24%. 6
7
Therefore, the 2018 pre-tax WACC = (56% * 4.47%) + (4% * 2.29%) + (40% * 12.24%) 8
= 2.5032% + 0.0916% + 4.896% 9
= 7.49% 10
11
b) Hydro One is unable to answer this question as we don’t have the data that was used to 12
compute the other utilities’ pre-tax WACC. 13
14
c) To determine the Joint Use Telecom Charge (Rate Code 30) over the application period, the 15
2018 WACC rate is used to determine the 2018 charge. The 2018 charge is then inflated 16
annually by the projected Implicit Price Index. 17
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S6
Page 1 of 2
Witness: BOLDT John
OEB Staff Interrogatory # S6 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 2 8
Updated Evidence: 2017-06-07, Exhibit H1, Tab 2, Schedule 4, page 103 9
10
Interrogatory: 11
Preamble: 12
13
In Section 5.0 of the Supplemental Evidence, Hydro One provided Pole Maintenance Cost of 14
$7.25: 15
16
5.0 Pole Maintenance Costs of $7.25 17
18
= [USoA 5120, as stated in G1-03-01, Attachment 3, Sheet I3 Trial Balance Data, Cell H392 19
($23,422,812.70)/ Qty. of Poles Extrapolated for 2018 (1,566,272) = $14.95]*Allocation to 20
Third Parties Determined by OEB (48.50%) = $7.25 21
22
and 23
24
Updated Evidence: 2017-06-07, Exhibit H1, Tab 2, Schedule 3, page 104 Hydro One provided: 25
26
3. 2016 Pole Maintenance Costs of $4.08 27
28
Lines Maintenance 29
30
USofA 5120: Maintenance of Poles, Towers and Fixtures 31
32
Sub Account 1464 - Trouble Calls ($14.14M) + Subaccount 1467 - OM&A Cost Storm 33
Response ($1.56M) + Subaccount 1469 - Defect Corrections ($1.34M) = $17.04M 34
$17.04M x 5% (5% of the time work is pole related) = $0.85M 35
36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S6
Page 2 of 2
Witness: BOLDT John
a) Why has account 5120 increased from $17.04 M to $23.4 M, a 37% increase in less than 2 1
years? 2
3
b) Please confirm whether the costs in subaccount 1464 as filed represent the breakdown of 4
costs in account 5120. 5
6
c) Does Hydro One have any indication that this account will keep increasing at this rate over 7
the next 5 years? 8
9
d) In its May 28, 2018 supplemental explanation of evidence, Hydro One has used an allocation 10
factor of 48.5% (as determined by OEB1) of account 5120 rather than 5% as per updated 11
evidence filed on June 7, 2017. In Hydro One’s view, does the 48.5% represent a more 12
accurate allocation for pole maintenance attributed to communication carriers for its pole 13
population? 14
15
e) Going forward, could Hydro One break out maintenance costs by sub account for joint-use 16
poles only? 17
18
Response: 19
a) USoA 5120 has not increased by 37%. The $17.04M filed in Exhibit H1-02-03, page 103 is 20
made up of only certain subaccounts, as further stated in H1-02-03, page 104 of 112. In 21
following the OEB’s methodology, the $23.04M filed in Hydro One’s Supplemental 22
Explanation, is the forecasted 2018 year-end balance of USoA 5120. 23
24
b) A portion of subaccount 1464 is allocated to USoA 5120, and for 2016, that portion is shown 25
in Exhibit H1-02-03, page 104 of 112. 26
27
c) The rate of increase calculated in a) is not accurate. Please refer to a) above. 28
29
d) Hydro One has applied the OEB’s methodology and pole maintenance cost allocation factor 30
for determining the telecom Joint Use rate. 31
32
e) Yes, it could be possible. 33
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S7
Page 1 of 2
OEB Staff Interrogatory # S7 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
Supplemental Explanation of Pole Attachment Rate Calculations, page 2 8
Evidence Updated: 2017-06-07, Exhibit H1, Tab 2, Schedule 4, page 103 9
10
Interrogatory: 11
Preamble: 12
13
In Section 7.0 of the Supplemental Explanation page 2, Hydro One provided the calculation of 14
the Average Number of Attachers Per Pole. 15
16
Average Number of Attachers Per Pole = (2018 Total Number of Permitted Poles for All 17
Attachers /Qty. of Joint Use Poles Extrapolated for 2018) = 726,240/537,719 = 1.35 18
19
a) Based on Hydro One’s proposed pole replacement program and planned mergers and 20
acquisitions of utilities, does Hydro One project the count to increase or decrease in the 21
upcoming 5 years or remain relatively stable? 22
23
b) If Hydro One is predicting a change in the count going forward, please provide a range. 24
25
Response: 26
a) When the three acquired utilities are integrated into Hydro One, the average number of 27
attachers per pole will remain relatively stable. 28
29
b) The three acquired utilities would result in an increase from 1.35 to 1.37 Average Number of 30
Attachers Per Pole. 31
32
Average Number of Attachers Per Pole = (2018 Total Number of Permitted Poles for All 33
Attachers, including three acquired utilities /Qty. of Joint Use Poles Extrapolated for 2018, 34
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule Staff-S7
Page 2 of 2
Witness: BOLDT John
including three acquired utilities) = (726,240+18,9161)/(537,719+5,811
2) = 745,156/543,530 1
= 1.37 2
1 I-42-VECC-58 shows the number of telecom attachments being integrated from the acquired LDCs. I-42-VECC-63 shows the
number of streetlight attachments being integrated from the acquired LDCs. 2 Poles integrated from acquired utilities: Norfolk Power – 3,072, Haldimand Hydro – 1,347, Woodstock Hydro – 1,392.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S130
Page 1 of 2
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S130 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable? 5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
11
Interrogatory: 12
a) With respect to Tab 3 of the Pole Attachment Work Form, please provide the 2017 actual 13
costs for GIS Tracking (Joint Use Database Maintenance) and provide a breakdown as 14
between: i) enhancement costs and ii) annual maintenance costs in the same level of 15
detail as shown under Item #1 on page 1 for 2018. 16
17
b) With respect to Item #1 on page 1, what is the basis for the 50 hours used to determine 18
the annual maintenance costs for 2018 and what were the actual hours for 2017? 19
20
c) Please provide the basis for the $181/hour rate used for 2018, including a schedule 21
showing the components of the rate. 22
23
d) Please describe the actual Joint Use Database enhancements performed in 2017 and those 24
planned for 2018. 25
26
e) What were the annual enhancement costs for the Joint Use Database for 2013-2016? 27
28
f) What were the actual number of annual maintenance hours and the resulting annual costs 29
for the Joint Use Database for 2013-2016? 30
31
Response: 32
a) i) There were no enhancement costs in 2017. 33
ii) Annual maintenance costs = 50 hours x $180/hour1 = $9,000 34
35
1 This is the fully burdened labour rate for 2017. In 2018, the fully burdened labour rate increased to $181/hour.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S130
Page 2 of 2
Witness: BOLDT John
b) The 50 hours are for ongoing maintenance to the database system that is used to track billing 1
information for joint use partners, and create, maintain and supersede permits. It is a web-2
based application used to track all executed joint use agreements. The actual hours for 2017 3
were 50 hours, as shown in 1. a) above. The maintenance team allocates approximately one 4
hour every week for Joint Use database maintenance. They address a number of issues 5
including: breaks in the code where the system goes down, permit applications which did not 6
upload properly, server maintenance, billing assistance for the joint use database billing 7
system. 8
9
c) This is a fully burdened labour rate for the staff performing Joint Use Database enhancement 10
work in 2018. The components of fully burdened labour rates are described in Exhibit C1-03-11
01-01. 12
13
d) There were no enhancements to the database in 2017. Enhancements completed in 2018 were 14
to provide new options for telecommunication companies in regards to standard deviations. 15
The specific items were: 16
i) Ability for Hydro One technicians to input the poles which have these deviations. 17
ii) Additional reports which can be run to provide the updates to the Electrical Safety 18
Authority for these deviations. 19
iii) Changes to all forms on the Joint Use Database to show the deviations to the users2. 20
iv) Added an additional search field in the Joint Use Database for the users to find permits by 21
streets. 22
23
e) The only enhancement was undertaken in 2016, at a cost of $22,400. 24
25
f) In the years 2013-2016, 50 hours has consistently been allocated to maintenance of the Joint 26
Use database, at that year’s appropriate labour rate. 27
2 The user of the form is primarily a technician, but the form may also be used by the Joint Use team or other employees inside
Hydro One
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S131
Page 1 of 2
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S131 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
11
Interrogatory: 12
a) With respect to Item #1 on page 1, what activities are included under Joint Use Staff 13
Specific Labour? In responding please confirm whether or not the activities include 14
issuance and management of permits, invoices and back office support activities. Please 15
also confirm whether these activities are associated just with telecom attachers or with all 16
third party attachers. 17
18
b) How was the forecast cost of $1,109,258.50 determined? 19
20
c) Please provide the annual Joint Use Staff Specific Labour costs for 2013-2017. 21
22
d) How were actual costs for each year determined? 23
24
Response: 25
a) The labour that has been submitted is the labour associated to the overall provincial Joint Use 26
program. The team monitors agreements, creates memos, resolves disputes, trains staff, 27
monitors permits, issues invoices, monitors accounts receivables, performs Regulation 22/04 28
audits, works with joint use standards, distribution rate filings and writes and negotiates new 29
agreements. These activities are associated with all attachers. Please also see I-54-Staff-30
S2(c). 31
32
b) $1,109,258.50 is the labour cost that will be incurred in 2018 by the provincial Joint Use 33
team at Hydro One. 34
35
36
37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S131
Page 2 of 2
Witness: BOLDT John
c) 1
Year Joint Use Staff Specific Labour Cost
2013 $1,026,373
2014 $1,080,772
2015 $1,114,082
2016 $1,242,163
2017 $1,151,190
2
d) These are the annual labour costs incurred by the provincial Joint Use team at Hydro One. 3
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S132
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S132 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
EB-2015-0304: Report of the Ontario Energy Board –Wireline Pole Attachment Charges 11
12
Interrogatory: 13
a) With respect to the Pole Attachment Working Group the OEB constituted to provide 14
input into the EB-2015-0304 Report, did HONI provide any data regarding historic 15
Administration Costs? 16
17
b) If yes, please provide the data and reconcile it with the historic data provided in response 18
to VECC 130 and VECC 131. 19
20
Response: 21
a) No. 22
23
b) Please see I-54-Rogers-S2 Q1 (d). 24
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S133
Page 1 of 2
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S133 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
11
Interrogatory: 12
a) With respect to Item #2 on page 1, please explain what DOMC and RLM stand for and 13
what the roles of each are in responding to trouble calls dispatched on behalf of telecom 14
carriers. 15
16
b) Do the trouble calls dispatched on behalf of telecom carriers include incidents related to 17
wires down, trees on wires and low wires? If not, what types of incidents are excluded 18
and why? 19
20
c) What other types of incidents could lead to trouble calls dispatched on behalf of telecom 21
carriers? 22
23
d) Please explain the basis for each of the “rates” used in the table and provide a schedule 24
setting out the components of each rate. 25
26
e) Please explain why the regular hour rates are materially lower than the rate used in the 27
determination of the annual maintenance costs for the Joint Use Database. 28
29
f) Please provide a table similar to that provided under Item #2, Tab 2 but using 2016 hours 30
data and 2018 labour dollars. 31
32
Response: 33
a) DOMC stands for Distribution Operations Maintenance Centre. The staff in the DOMC will 34
retrieve trouble calls from the customers, and dispatch the crews to address the trouble call. 35
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S133
Page 2 of 2
Witness: BOLDT John
RLM stands for Regional Line Maintainers. They are the workers that respond to the trouble 1
call. 2
3
b) Yes. 4
5
c) Hydro One responds to any trouble calls related to a telecom related asset that is relayed to us 6
from an Ontario resident or a first responder. Hydro One does not have the ability to 7
determine if it is only telecom related at the time that the call is received. To positively 8
identify, a trouble truck is dispatched to the location, and if hazardous, the Hydro One crew 9
will control the hazard for the safety of the public and notify the appropriate carriers. 10
11
d) The composition of the rates is described in C1-03-01, Attachment 1 for labour rates, and 12
C1-03-01, Attachment 2 for fleet rates. 13
14
e) Different staff with a different labour rate performs the annual maintenance costs for the 15
Joint Use Database. 16
17
f) Below is the requested information. Note, Hydro One received fewer trouble calls in respect 18
of telecom assets in 2016 than in 2017. 19
20
21
22
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S134
Page 1 of 2
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S134 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
11
Interrogatory: 12
a) With respect to the Table under Item #2 on page 1, please confirm that the table only 13
includes trouble calls dispatched that involved telecom carriers’ facilities. 14
15
b) If confirmed in part (a), would there have been other trouble calls dispatched that were 16
related to lines/equipment owned by other 3rd
party attachers? 17
18
c) Please explain why, if the trouble call volumes are based on trouble calls associated only 19
with telecom carriers’ facilities, the cost per pole for Trouble Calls (i.e., $3.20) is 20
calculated using the total number of 3rd
party attachers per pole as opposed to just the 21
number of telecom carrier attachers per pole. 22
23
Response: 24
a) Confirmed. 25
26
b) Yes, Hydro One does dispatch trouble calls related to lines and equipment owned by other 3rd
27
party attachers. The times associated with these trouble calls are not included in the Table 28
under Item #2 on page 1. 29
30
c) In accordance with the OEB workform, we used the total joint use poles and the associated 31
allocation factor to determine the Loss of Productivity rate. 32
33
Correction to Supplemental Evidence 34
In Hydro One’s submission on May 28, 2018, we submitted that the Total Cost of Wires 35
Down that Hydro One incurred on behalf of telecom carriers was $2,321,078.13, and that 36
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S134
Page 2 of 2
Witness: BOLDT John
was calculated based on 2017 trouble call data. Our submission stated that we applied 2018 1
labour rates to determine the amount. In error, 2017 labour rates were used in that 2
calculation. 3
4
Using the 2018 labour rates, with the 2017 trouble call data, the Total Cost of Wires Down 5
amount comes to $2,336,836.55. This would increase the Total Loss of Productivity, per 6
pole, per attacher by two cents, to $3.22, and would also increase the 2018 pole attachment 7
charge by two cents from $47.67 to $47.69. 8
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S135
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S135 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 1 9
HONI Pole Attachment Work Form, Tab 3 (Direct Costs) 10
11
Interrogatory: 12
a) Are there any other activities that HON undertakes specifically on behalf of telecom 13
carriers that are classified as OM&A as opposed to capital expense? 14
15
b) Are there any other OM&A-related activities that HON performs on its own distribution 16
assets where there are incremental costs directly as a result of the existence of telecom 17
attachers? If so, what are they and what are the estimated incremental costs for 2017? 18
19
Response: 20
a) In the OEB’s decision, the OEB did not include costs for primary neutrals, copper down 21
grounds and grounding rods, which Carriers bond/connect to based on CSA standards. Hydro 22
One has not submitted them following the OEB approved work form. 23
24
b) No. 25
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S136
Page 1 of 4
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S136 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, pages 1-2 9
HONI Pole Attachment Work Form, Tab 2 (Attacher and Pole Data) 10
11
Interrogatory: 12
a) Please provide data similar to that in Tab 2 (Tables 1, 2 and 3) for each of the years 2013-13
2016. 14
15
b) With respect to footnote 1 on page 1, please provide the calculations supporting the 16
assumed average increase of 12,227 in Joint Use Poles per year and the assumed average 17
annual increase of 1,644 in Total Poles per year. 18
19
c) With respect to Table 1 in Tab 2, please confirm that the volumes represent the number 20
of attachers and not the number of attachments on HONI poles. If not, please provide a 21
revised Tables 1 and 3 for 2013-2018 based on the number of attachers. 22
23
d) With respect to Table 1 in Tab 2, are the volumes for non-telecom attachers based on: i) 24
the number of attachers regardless of whether or not the pole concerned has a telecom 25
attacher or ii) the number of attachers on poles that also have a telecom attacher? 26
27
e) If Table 1 in Tab 2 sets out the number of non-telecom attachers on all HONI poles 28
regardless of whether or not there is a telecom attacher (i.e., case (i)), please provide a 29
revised Table 1 based on case (ii) that sets out the values for 2013-2017. (Note: Please 30
also ensure the tables reflect attachers and not attachments). 31
32
f) With respect to Table 1 in Tab 2, please clarify whether: i) there are no traffic lights 33
attached to HONI poles; ii) there are traffic light attachers but they are included under 34
street lighting or iii) there are traffic lights attached but no “charge” is levied. 35
If case (i), please reconcile with the response to EB-2015-0141, Exhibit I, Tab 4, 36
Schedule 1 c) which indicates that HONI has agreements with municipalities 37
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S136
Page 2 of 4
Witness: BOLDT John
regarding traffic light attachments. 1
If case (ii), please reconcile the number reported for 2017 of 77,341 with the 2015 2
value of 101,859 reported in EB-2015-0141, Exhibit I, Tab 4, Schedule 1 d). 3
Also, please separate out the number of street lights vs. traffic lights for 2013-4
2018 5
If case (iii) please reconcile with the response to EB-2015-0141, Exhibit I, Tab 4, 6
Schedule 1 c) which indicates that HONI has agreements that set the rate at $2.04 7
per year. Also, please provide the number of traffic light attachers for 2013-2018. 8
9
g) With respect to Table 1 in Tab 2, does the row “LDC Generator” include both LDC 10
power attachers as well as Generator power attachers? If yes, please provide a 11
breakdown. If not please explain where each of these two types of attachers are 12
accounted for in Table 1. 13
14
h) With respect to Table 1 in Tab 2, please break the 302,268 telecom attachers/attachments 15
reported for 2017 down into the various categories used in the response to EB-2015-16
0141, Exhibit JT3 (i.e., Full Telecom, Telecom Service and Bell MEU). If Telecom 17
Service Poles or Bell MEU poles are not included in Table 1 please: i) explain why not; 18
ii) indicate the number of such attachments for 2017; and iii) indicate the current rate 19
paid. 20
21
i) Are there any other third party attachers to HONI’s poles that have not been included in 22
Table 1? If so please indicate: i) who they are; ii) the volumes in 2017 (based on 23
attachers not attachments) and iii) the rate paid (if any). 24
25
Response: 26
a) Hydro One began tracking data at this level beginning in 2016. Please see below for the data 27
in Tab 2, Tables 1 through 3 for 2016. See also in I-54-Staff-260(b) which includes similar 28
information for attacher data only. 29
30
Type of Attacher 2016 Actual Volumes
Telecom Attacher 300,126
Bell Canada 331,238
Streetlights 83,238
LDC & Generators 15,176
Total 729,778
31
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S136
Page 3 of 4
Witness: BOLDT John
b) Please see the tables below as well as I-54-Rogers-S04: 1
2
3
4
5
c) Confirmed. 6
7
d) Confirmed that i) is correct, the numbers in Table 1 reflect the number of attachers regardless 8
of whether or not the pole concerned has a telecom attacher. 9
10
e) Please see I-54-Rogers-S2 Q1 (d). 11
12
f) Confirmed that ii) is correct. There was an internal audit on streetlights performed to confirm 13
the number of lights being billed to municipalities, and the number was corrected in 2017. 14
We do not track streetlights separately from traffic lights. 15
16
g) LDCs are attached to 10,144 poles for power space, and Generators are attached to 4,123 17
poles for power space. 18
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S136
Page 4 of 4
Witness: BOLDT John
h) Please see I-54-Rogers-S2 Q1 (d). 1
2
i) No. 3
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S137
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S137 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, pages 1-2 9
HONI Pole Attachment Work Form, Tab 2 (Attacher and Pole Data) 10
11
Interrogatory: 12
a) With respect to Table 2 in Tab 2, are the volumes shown for Joint Use Poles based on: i) 13
the number of joint use poles regardless of whether or not the pole concerned has a 14
telecom attacher or ii) the number of joint use poles that have a telecom attacher? 15
16
b) If Table 2 in Tab 2 sets out the number of joint use poles regardless of whether or not 17
there is a telecom attacher (i.e., case (i)), please provide revised Joint Use Pole data per 18
Table 2 based on case (ii) for each year 2013-2017. 19
20
Response: 21
a) The volumes shown for Joint Use poles are based on i) the number of joint use poles 22
regardless of whether or not the pole concerned has a telecom attacher. 23
24
b) Please see I-54-Rogers-S2 Q1 (d). 25
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S138
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S138 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, pages 1-2 9
HONI Pole Attachment Work Form, Tab 4-a (Power Deduction Factor) 10
11
Interrogatory: 12
a) Did HONI attempt to complete Tab 10 a) in Tab 4-a based on HONI’s information? If 13
not, why not? 14
15
b) If yes, please provide the results. 16
17
Response: 18
a) HONI did not attempt to complete Table 10 in Tab 4-a because HONI already showed the 19
derivation of the 15% during the Pole Attachment Working Group (“PAWG”) meetings, and 20
accepts the OEB’s direction at 15% to remove power related fixtures. Please see the 21
instructions at the top of Tab 4a) which state: “Instructions: If a change to the default 22
allocation of 15% power deduction is proposed, please complete Table 10-a”. 23
24
b) N/A 25
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S139
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S139 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 2, Item 4 9
HONI Pole Attachment Work Form, Tab 4 (Indirect Costs) 10
Exhibit D2, Tab 1, Schedule 1, Attachment 1, page 5 11
12
Interrogatory: 13
a) Please provide the derivation of the $54 M depreciation expense shown for Account 1830 14
for 2018 (per Exhibit D2., Tab 1, Schedule 1, Attachment 1) and, in doing so, show the 15
depreciation rate used. 16
17
b) What was the applicable depreciation rate for Account 1830 for each of the years 2013-18
2017? 19
20
Response: 21
a) The 2018 forecasted depreciation expense was derived below, using the half-year rule for 22
additions and disposals to the asset base. 23
24
2018 YE Asset Base $ 3,200.7
x Depreciation rate 1.70%
Depreciation Expense $ 54.4
25
b) The depreciation rate for Account 1830 was1: 26
a. 2013-2014: 1.83% 27
b. 2015-2017: 1.7% 28
1 EB-2013-0416 C1-06-01 Attachment 1 page 22.
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S140
Page 1 of 3
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S140 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 2, Item 6 9
HONI Pole Attachment Work Form, Tab 1 (Summary Tab) 10
11
Interrogatory: 12
a) Please provide the derivation of the 2018 Before Tax Weighted Average Cost of Capital 13
(7.49%) including references to where in the Application the various inputs used can be 14
found. 15
16
b) What was HONI’s 2017 Before Tax Weighted Average Cost of Capital based on its 17
actual 2017 cost of debt, the Board’s approved return on equity for 2017 and the Board’s 18
approved capital structure. Please provide the derivation. 19
20
c) HONI is proposing to update its cost of capital calculation in 2021. Does HONI plan to 21
revise the Pole Attachment Charge calculation in 2021 to reflect the updated value for the 22
Before Tax Weighted Average Cost of Capital? 23
24
Response: 25
a) The pre-tax WACC is calculated as follows: 26
Pre-tax WACC = (Target Long Term Debt Ratio * Medium & Long Term Borrowing Rate) 27
+ (Target Short Term Debt Ratio * Short Term Borrowing Rate) + (Target Equity Ratio * 28
Target Before Tax Return on Equity) 29
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S140
Page 2 of 3
Witness: BOLDT John
The rates below, also filed in EB-2017-0049, Exhibit Q, Tab 1, Schedule 1, Section 1.3, Table 8, 1
show the Hydro One rates for 2018: 2
3
Distribution WACC 2017 2018
Rates
Short term borrowing rate 1.76% 2.29%
Medium & Long Term Borrowing Rate 4.43% 4.47%
Allowed Return on Equity 8.78% 9.00%
Capital structure
Target Short-term debt ratio 4.00% 4.00%
Target Long-term debt ratio 56.00% 56.00%
Preferred shares 0.00% 0.00%
Target Equity Ratio 40.00% 40.00%
Proxy Income Tax Rate 26.50% 26.50%
Pre-tax WACC 7.33% 7.49%
4
The 2018 target pre-tax Return on Equity is calculated as follows: Allowed Return on Equity/(1-5
Proxy Income Tax Rate) = 9.00%/(1-26.50%) = 9.00%/73.50% = 12.24%. 6
7
Therefore, the 2018 pre-tax WACC = (56% * 4.47%) + (4% * 2.29%) + (40% * 12.24%) 8
= 2.5032% + 0.0916% + 4.896% 9
= 7.49% 10
11
See also I-54-Staff-S5(a). 12
13
b) The 2017 Before Tax Weighted Average Cost of Capital was 7.33%. Please see below for the 14
derivation. 15
Distribution WACC 2017
Rates
Short term borrowing rate 1.76%
Medium & Long Term Borrowing Rate 4.43%
Allowed Return on Equity 8.78%
Capital structure
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S140
Page 3 of 3
Witness: BOLDT John
Target Short-term debt ratio 4.00%
Target Long-term debt ratio 56.00%
Preferred shares 0.00%
Target Equity Ratio 40.00%
Proxy Income Tax Rate 26.50%
1
As shown in I-54-Staff-S5(a), the pre-tax WACC is calculated as follows: 2
Pre-tax WACC = (Target Long Term Debt Ratio * Medium & Long Term Borrowing Rate) + 3
(Target Short Term Debt Ratio * Short Term Borrowing Rate) + (Target Equity Ratio * Target 4
Before Tax Return on Equity) 5
6
The Target Before Tax Return on Equity is calculated as follows: 7
Allowed Return on Equity/(1-Proxy Income Tax Rate) = 8.78%/(1-26.50%) = 8.78%/73.50% = 8
11.95%. 9
10
Therefore, the pre-tax WACC is: = (56% * 4.43%) + (4% * 1.76%) + (40% * 11.95%) 11
= 2.4808% + 0.0704% + 4.776% 12
= 7.33% 13
14
c) No. Hydro One’s submissions request to use the 2018 WACC rate to determine the 2018 15
charge and then to inflate the 2018 charge annually by the projected Implicit Price Index. 16
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S141
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S141 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 2, Item 7 9
HONI Pole Attachment Work Form, Tab 2 (Attacher and Pole Data) 10
11
Interrogatory: 12
a) Are all of the attachers shown in Table 1 (Tab 2) located in the telecom 13
(communications) space? If not, please provide a schedule setting out, for 2017, the 14
number of each type of attacher located in the telecom space. Please also confirm the 15
location of the balance of the attachers. 16
17
Response: 18
a) No. 19
20
Only telecom attachers are located in the telecom space. There are 633,506 attachers in the 21
telecom space. 22
23
The LDCs and generator attachers are located in the power space. The streetlight attachers 24
are located above the telecom space. 25
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S142
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S142 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Supplemental Explanation of Pole Attachment 8
Rate Calculations, page 2, Item 7 9
HONI Pole Attachment Work Form, Tab 2 (Attacher and Pole Data) 10
EB-2015-0304: Report of the Ontario Energy Board –Wireline Pole Attachment Charges, 11
pages 32-33 12
13
Interrogatory: 14
Preamble: 15
16
The Board Report’s discussion of Nordicity’s “hybrid methodology” assumes that all third 17
party attachers are located in the communications space. This is evidenced by the fact the 18
discussion assumes space related directly to third party attachers is the 2 feet of 19
communications space plus the 3.25 feet of separation space. 20
21
a) Does HONI accept the premise set out in the above Preamble? If not, why not? 22
23
b) Please recalculate the allocation factor where the portion of the space attributable to 24
communication space users (i.e., 100% of the communications and separation space plus 25
50% of the common space) is divided by the number of attachers per pole in the 26
communications space. 27
28
Response: 29
a) Please see I-54-Rogers-S2 Q1 (d). 30
31
b) Please see I-54-Rogers-S2 Q1 (d). 32
Filed: 2018-08-23
EB-2017-0049
Exhibit I
Tab 54
Schedule VECC-S143
Page 1 of 1
Witness: BOLDT John
Vulnerable Energy Consumers Coalition Interrogatory #S143 1
2
Issue: 3
Issue 54: Are the proposed specific service charges for miscellaneous services over the 2018 – 4
2022 period reasonable?5
6
Reference: 7
HONI’s Reply to Procedural Order No. 6, Explanation of Pole Attachment Rate Calculations, 8
page 3 9
10
Interrogatory: 11
a) Please confirm that HONI is requesting the OEB to approve (on a final basis) the 2019-12
2022 Pole Attachment Charges set out on page 3. If not, what is HONI’s proposal 13
regarding the determination and approval of the Pole Attachment Charges for 2019-14
2022? 15
16
b) Why isn’t HONI requesting that the 2019-2022 Charges be determined by applying the 17
annual IPI value as approved by the Board? 18
19
Response: 20
a) Yes. 21
22
b) HONI is projecting the rate for 2019-2022 based on forecasted IPI to offer the 23
telecommunications companies the ability to forecast their future expenses. 24